"6. As described more fully below, in or about the
summer of 2010, Full Tilt Poker’s payment processing channels
were so disrupted that the company faced increasing difficulty
attempting to collect funds from players in the United States.
Rather than disclose this fact, Full Tilt Poker simply credited
players’ online gambling accounts with money that had never
actually been collected from the players’ bank accounts. Full
Tilt Poker allowed players to gamble with -- and lose to other
players -- this phantom money that Full Tilt Poker never actually
collected or possessed. When other players won these phantom
funds, their accounts were credited with money that Full Tilt
Poker did not actually possess, but now nevertheless owed to
these players. As a result, Full Tilt Poker soon developed a
massive shortfall between the money owed to United States players
and the money actually collected from United States players, with
Full Tilt Poker having credited approximately $130 million in
phantom money to U.S. players’ online accounts that was never
actually collected from players’ bank accounts. Full Tilt Poker
never disclosed this shortfall to the public."